ESMA has published the sixteenth update of its Q&As on the implementation of EMIR, following its revised version earlier this month. The new questions relate to Article 4(1)(b)(ii) of EMIR, concerning the frontloading requirement for the clearing obligation, Article 4 of EMIR, relating to the types of novation that would trigger the clearing obligation and whether the clearing obligation applies to a swap that results from the exercise of a swaption, as well as questions relating to default management of CCPs, NCA access to trade repository data and reporting of notional in position reports.